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Marshalls Plc
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Period ending December 2022
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Marshalls plc
END MODERN SLAVERY END MODERN SLAVERY ENDModernMODERNSlavery StatementSLAVERYto DecemberEND2022 MODERN ERN SLAVERY END MODERN SLAVERY END MODERN SLAVERY END MODERN SLAVERY
Introduction
This statement applies to activities within Marshalls Group plc between January and December 2022. Marshalls acquired Marley Group plc in April 2022. We are working towards more integrated reporting in our 2023 statement.
Marshalls' Annual Modern Slavery Statement has full Board approval. As a UK-based business with global supply chains, we are committed to doing all that we can to eliminate modern slavery. This is woven through our structures and operations, our engagement with our people, suppliers, customers, and reflected in our commitment to ethical procedures and to upholding the UN Guiding Principles on Business and Human Rights.
Modern slavery remains firmly at the top of our organisational agenda. The Board is well aware that the impact of the pandemic continues to reverberate in global supply chains and has had significant impact upon workers in supply chains. We understand that the situation has been compounded further by the war in Ukraine, the cost-of-living crisis, volatility and uncertainty in energy supply and price; a few among many other extremely unsettling factors.
Our partnerships and work with the United Nations Global Compact, the International Organization for Migration and the International Labour Organization, and with workers' bodies and associations, ensure that we are fully aware of the situation of workers and communities both in the UK and overseas. We recognise the private sector's important role in respecting human rights, ensuring decent work and economic growth, as well as supporting and upholding international standards.
We continue to actively support the calls for, and movement towards, mandatory human rights and environmental due diligence because we believe strongly that this is the right path for any business committed to operating responsibly. The trajectory of global human rights legislation and the pace of change continue to fuel our efforts and keep up momentum. In 2022, we increased the capacity of our business and human rights team as we go deeper and into more of our supply chains in order to find, fix and prevent modern slavery.
Having acquired Marley in April 2022 the expanded team is working to integrate them into the Group business and human rights roadmap to 2030, sharing and embedding the strong and effective human rights and environmental due diligence systems and processes that we've developed over a number of years. Next year's Modern Slavery Statement will fully reflect this integration process.
I, and the Board, remain wholly committed to our efforts to eliminate modern slavery in all of its forms.
Martyn Coffey
Marshalls CEO
15th March 2023
Highlights from the past
Continued to review, revise and strengthen our procurement human rights due diligence system and our processes.
Expanded our business and human rights team to increase capacity for risk assessment, supplier visits and engagement.
Continued to deepen our engagement with suppliers in higher risk supply chains, and in higher risk geographies.
Undertook advanced supply chain mapping for 100% of our natural stone supply chains, using risk analysis tools supplied by Verisk Maplecroft.
Introduced a human rights and environmental due diligence analysis process that maps supplier locations against in-country and regional human rights risks.
Engaged with local experts to map out our South Indian supply chain back to raw materials and to analyse current and evolving human rights risks, providing procurement with more detailed information to aid decision making.
Worked with our China office to map out our entire natural stone supplier locations to quarry level.
Delivered a project with the IOM in Vietnam to understand the effect that the Covid-19 pandemic had on the natural stone sector, and the support that local companies require to meet international standards. This is building on a collaborative relationship that began in 2019.
Started piloting the Everyone's Business app for onsite reporting in China, in preparation for wider rollout in 2023 with other colleagues across the Group.
12 months
Carried out a human rights risk assessment of aggregates and minerals suppliers in our materials supply chain.
Continued with the implementation of an independent Modern Slavery Threat Assessment programme throughout our UK operations, covering 32 Marshalls locations in 2022.
Established an ESG Steering Committee attended by senior directors, at which our approach to modern slavery will increasingly be scrutinised internally.
Refreshed our Code of Conduct for Marshalls employees and suppliers, with added emphasis on whistleblowing and human rights
due diligence.
Published our Risk Analysis Report which shows sourcing geographies for all of our locations, making this publicly available.
Continued our engagement with the UN Global Compact PACE project to eliminate the worst forms of child labour.
Co-chaired the ILO Child Labour Platform India Working Group, working in a cross-sectoral initiative.
Supported a multi-lateral consultation in Brussels on the health of Indian workers in the quarrying and mining sector, with the Rajasthan Mine Workers Welfare Board.
Funded and supported the launch of a publicly available podcast series organised by the Social Responsibility Alliance which explores the complex challenges businesses face in identifying modern slavery and human trafficking risks, evidencing those risks and making the necessary changes.
Presented at a Cabinet Office-sponsored event for government suppliers on the risks of modern slavery on construction sites.
Continued to engage with UK Government, the UK Migration and Modern Slavery Envoy, the Commonwealth Parliamentary Association, overseas governments, international business associations and bodies on the issues of modern slavery.
Continued to support the Cabinet Office's UK Modern Slavery Training Delivery Group.
Continued to provide intelligence to law enforcement in the UK, including the Gangmasters & Labour Abuse Authority (GLAA), local law enforcement, the Modern Slavery Helpline.
Continued to work with Bright Future, offering employment opportunities to victims of modern slavery in the UK.
Contents
Areas of activity | 2 | |
How Marshalls does business | 3 | |
Our commitment to UK Modern Slavery Law | ||
I. | The organisation's structure, its business | 6 |
and its supply chains | ||
II. | Policies in relation to slavery and | 9 |
human trafficking | ||
III. | Due diligence processes in relation to slavery | 12 |
and human trafficking in its business and | ||
supply chains | ||
IV. | The parts of its business and supply chains | 14 |
where there is a risk of slavery and human trafficking | ||
taking place, and the steps it has taken to assess | ||
and manage that risk | ||
V. | Its effectiveness in ensuring that slavery | 15 |
and human trafficking is not taking place in its business | ||
or supply chains, measured against such performance | ||
indicators as it considers appropriate | ||
VI. | The training available to staff | 16 |
More information | 17 | |
Find out more about Marshalls at: marshalls.co.uk/about-us
All of this activity is documented in detail in our 2021 End Modern Slavery Report. Download it at:
marshalls.co.uk/sustainability/modern-slavery
Marshalls plc | 1 |
Modern Slavery Statement to December 2022 |
Areas of activity
Focus | Activity | |
Strategic | Develop/support/engage | Activity and deepened engagement with the ILO Child Labour Platform. |
collaboration to | in strategic collaborations/ | Co-Chairing of UK Government Modern Slavery Training Delivery subgroup, focusing |
accelerate the | partnerships/initiatives to | upon construction, transport and logistics. |
identify, prevent and mitigate | ||
eradication of | Continuing engagement with the UN Global Compact (UNGC) to support global | |
human rights abuses in | ||
eradication of modern slavery. | ||
modern slavery | Marshalls' own business | |
Continuing active engagement with the UNGC PACE investor initiative, focusing on the | ||
operations and global supply | ||
worst forms of child labour and exploring how learnings can more broadly be applied | ||
chains; build knowledge, | ||
to other fragile communities. | ||
capacity and facilitate | ||
Continue to work with the IOM in Vietnam, carrying out a project to understand the | ||
engagement from/with the | ||
wider construction sector and | impact of Covid-19 on local stone supply chains. | |
across sectors, as appropriate. | Continue to engage with the Dutch and Flemish Government's responsible production | |
and purchase of natural stone initiative, TruStone. | ||
Support and engage in the work of CCLA Find it, Fix it, Prevent it investor initiative. | ||
Further develop the work of the internal Business and Human Rights Accelerator Group | ||
to aid the embedding, implementation and delivery of the BHR Roadmap to 2030. | ||
Engage with universities to support and facilitate research regarding modern slavery | ||
and human trafficking. | ||
Active engagement with the Social Responsibility Alliance to develop internationally | ||
recognised supplier engagement tools. |
Remediation and support for victims/ survivors
Implement appropriate remediation action to ensure that victims of modern slavery, identified within our own business operations and supply chains, can access the appropriate support, and that we offer support more widely as appropriate.
Review and strengthen our process of remediation and support for 85% of the supply chain identified as high risk, by volume of product for natural stone.
Review grievance mechanism and develop multi-language engagement materials ready for rollout of Safecall to strategic suppliers in 2023.
Increase in-country presence and live monitoring.
Human rights due diligence systems
Continuously improve our human rights due diligence systems and processes, and encourage the identification of instances of modern slavery - taking appropriate action to report and also to ensure that the most vulnerable are not further adversely affected.
Roll out of enhanced human rights and environmental due diligence (HREDD) supplier systems and processes.
Further refinement of our supplier risk analysis and resulting action following Slavery and Trafficking Risk Template (STRT) implementation.
Advanced supply chain network mapping - against global human trafficking data - for high risk suppliers.
Continue with specific work researching and mapping Chinese natural stone supply chain.
Further progress with our enhanced Modern Slavery Risk Assessment programme across UK business operations.
Implementation of a risk-based social audit programme for suppliers in 2023.
Effectiveness in identifying and preventing slavery
Report on our efforts and effectiveness in helping to ensure that modern slavery and human trafficking is not taking place in our business operations and global supply chains.
Trial the Everyone's Business app for roll out with wider procurement team. Roll out of Safecall whistleblowing hotline in key geographies for natural stone supply chains.
Expand advanced supply chain risk analysis to assist with prevention and identification.
Collaboration on the Vietnamese natural stone sector with the IOM; assessing recruitment and employment practices post Covid -19, promoting ethical standards.
Reporting on efforts to address root causes
Report on our efforts to address the root causes of salient human rights issues; child labour, bonded labour, prison labour and forced labour.
Continue to share with appropriate stakeholders, agencies, authorities, platforms and associations, our research, findings and insights as a result of our activity with UN partners, NGOs and others.
Continue to engage with governments to provide evidence and intelligence,
and to push for mandatory HREDD and the engagement in private sector efforts. Continue to work to deliver the 'Guiding Framework' within our IYECL Action Pledge.
Delivery of modern slavery training, and its impact
Enhance, develop, shape and deliver modern slavery training which empowers and assists internal decision making in support of human rights, and increases the reporting of instances of modern slavery.
Active engagement in the development, shaping and delivery of modern slavery training in the UK - across sectors - using IT.
Bespoke training for HR, procurement, operations and environmental teams. Knowledge partner accelerator programme with internal colleagues.
Roll out of modern slavery and ethical training for suppliers in four languages. Continue to actively engage with the Modern Slavery Training and Development Group. Refreshed anti-slavery training delivered in person in Marshalls locations.
Specialised training for the procurement team.
Preparatory work for the role of the Ethical Risk Index for roll out in 2023, highlighting risks in supply chains to domestic customers and clients. Training the commercial team on human rights in supply chains to encourage more conversations with customers.
2 | Marshalls plc |
Modern Slavery Statement to December 2022 |
How Marshalls does business
The Marshalls group of companies (including Marshalls plc and its direct and indirect subsidiaries, referred to in this Statement as "Marshalls"), wherever it operates around the world, is committed to: conducting business responsibly and with honesty and integrity; treating all people with dignity and respect; and complying with applicable laws, regulations and treaties.
Marshalls is also committed to protecting and promoting human rights globally. Marshalls does not tolerate child labour, forced labour, including prison labour, or any use of force or other forms of coercion, fraud, deception, abuse of power or other means to achieve control over another person for the purpose of exploitation.
Marshalls respects international principles of human rights including, but not limited to, those expressed in the UN Declaration of Human Rights, the UN Guiding Principles on Business & Human Rights, United Nations Global Compact Principles, Children's Rights and Business Principles, Women's Empowerment Principles and those principles contained within the UK's Modern Slavery Act 2015. These principles and commitments are now embodied in Marshalls' Supplier Code of Conduct, which can be accessed via our document library.
marshalls.co.uk/sustainability/ document-library
Marshalls complies with employment laws in every country in which it operates and expects those with whom it does business to do the same. Marshalls also complies with national and international laws governing issues of supply chain management and expects those with whom it does business to do the same. Our Code of Conduct specifies supplier obligations regarding modern slavery and human trafficking.
The UK Modern Slavery Act 2015 requires Marshalls to disclose annually online,
as a minimum, the following:
I | The organisation's structure, its | see | 6 |
business and its supply chains | page | ||
II | Its policies in relation to slavery | see | 9 |
and human trafficking | page | ||
Its due diligence processes in | |||
III | relation to slavery and human | page12 | |
trafficking in its business and | |||
see | |||
supply chains | |||
The parts of its business and | |||
supply chains where there is | |||
a risk of slavery and human | |||
IV | trafficking taking place, and | page14 | |
the steps it has taken to assess | |||
see | |||
and manage that risk | |||
Its effectiveness in ensuring that | |||
slavery and human trafficking is | |||
not taking place in its business or | page15 | ||
V | supply chains, measured against | ||
such performance indicators as | see | ||
it considers appropriate | |||
The training available to its | |||
staff involved in supply chain | |||
VI | management and employees | ||
throughout the rest of the | see | ||
organisation | page16 |
Marshalls plc | 3 |
Modern Slavery Statement to December 2022 |
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Marshalls plc published this content on 13 April 2023 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 13 April 2023 07:44:05 UTC.
